NCG170406_NOD_20220822

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
BRIAN WRENN
Director
CERTIFIED MAIL: 7018 0040 0000 4771 9602
RETURN RECEIPT REQUESTED
Kordsa, Inc.
Attn: Durul Bozbey, Plant Manager
17780 Armstrong Road
Laurel Hill, NC 28351
NORTH CAROLINA
Environmental Quality
August 22, 2022
Subject: NOTICE OF DEFICIENCY (NOD-2022-PC-0131)
NPDES Stormwater General Permit NCG170000
Kordsa, Inc.
Kordsa Laurel Hill, Certificate of Coverage NCG170406
Scotland County
Dear Mr. Bozbey:
On August 10, 2022, Mike Lawyer, Environmental Program Consultant with the Fayetteville Regional Office of the Division
of Energy, Mineral and Land Resources (DEMLR), conducted a site inspection for the Kordsa Laurel Hill facility located at
17780 Armstrong Road, Laurel Hill, Scotland County, North Carolina. A copy of the Compliance Inspection Report is
enclosed for your review. Mr. Miles Jorgensen, Environmental Engineer, and Ms. Donna Locklear, SHE Specialist, were
also present during the inspection and their time and assistance is greatly appreciated. The site visit and file review revealed
that the subject facility is covered by NPDES Stormwater General Permit NCG170000 under Certificate of Coverage
NCG170406. Permit coverage authorizes the discharge of stormwater from the facility to receiving waters designated as
Gum Swamp Creek (Ida Mill Pond), class C;Sw water in the Lumber River Basin.
As a result of the site inspection, the following deficiency is noted:
1) Qualitative Monitoring of Stormwater Discharges
Per Part II, Section C... Qualitative monitoring has not been conducted and/or recorded in accordance with permit
requirements. Specifically, monitoring was not conducted during Period 2 (July 1 — December 31) of 2021.
Other Observations
Please refer to the enclosed Compliance Inspection Report for additional comments and observations made during the
inspection.
Requested Response
A written response is not requested at this time.
Action Items
Conduct and record monitoring per the conditions of the permit.
North Carolina Department of Environmental Quality I Division of Energy, Mineral and Land Resources
E Fayetteville Regional Office 1 225 Green Street, Suite 714 1 Fayetteville, North Carolina 28301
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Thank you for your attention to this matter. This office requires that the deficiencies, as noted above and detailed in
the enclosed inspection report, be properly resolved. Failure to address the deficiencies could result in the
issuance of a Notice of Violation, which is subject to a civil penalty assessment of up to $25,000 per day for each
violation. Should you have any questions or concerns, please contact Mike Lawyer at [phone] or via email at
[e-mail].
Sincerely,
�fimothy L. LaBoun E
Regional Engineer
DEMLR
TL/ml
Enclosure: Compliance Inspection Report
ec: J. Miles Jorgensen, Environmental Engineer — Kordsa, Inc.
Donna Locklear, SHE Specialist— Kordsa, Inc.
Melanie Krause — Kordsa, Inc.
Toby Vinson, Jr., PE, CPESC, CPM, Chief of Program Operations — DEMLR
Brad Cole, PE, Chief of Regional Operations — DEMLR
Danny Smith, Supervisor— DEMLR, Stormwater Program
Brittany Carson, General Industrial Stormwater Permit Coordinator— DEMLR, Stormwater Program
DEMLR NPDES Stormwater Permit Laserfiche File
cc: FRO — DEMLR, Stormwater Files

Compliance Inspection Report
Permit: NCG170406 Effective: 08/01/19 Expiration: 05/31/24 Owner: Kordsa Inc
SOC: Effective: Expiration: Facility: KORDSA Laurel Hill
County: Scotland 17780 Armstrong Rd
Region: Fayetteville
Laurel Hill NC 28351
Contact Person: J Miles Jorgensen Title: Environmental Engineer Phone: [phone]
i
Directions to Facility:
From westbound Rt. 74, turn north (rt) on Armstrong Road. Continue on Armstrong Road for approx. 0.5 miles. Facility is on the left.
System Classifications: SWNC,
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
On -site representative J Miles Jorgensen 423-643-2759
On -site representative Donna Locklear 910-827-2679
Related Permits:
Inspection Date: 08/10/2022 Entry Time 0 35AM Exit Time: 12:03PM
Primary Inspector: Mike Lawys�Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Textile Mill Products Stormwater Discharge COC
Facility Status: ❑ Compliant E Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Page 1 of 3

N
Permit: NCG170406 Owner - Facility: Kordsa Inc
Inspection Date: 08/10/2022 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Met with Miles Jorgensen, Environmental Engineer, and Donna Locklear, SHE Speciaist, who provided the facility's
Stormwater Pollution Prevention Plan (SWPPP) and Qualitative Monitoring records for review. The SWPPP appeared to
contain all required components as well as forms documenting facility inspections, employee training, spill history (none),
etc. Based on the monitoring records available for review, Qualitative Monitoring of the facility's two stormwater discharge
outfalls was conducted and recorded semi-annually in 2019 and 2020, the first half of 2021 (missed second half), and so far
the first half of 2022. After the records review, observations were made of the facility's stormwater outfalls, ASTs with
secondary containment, retention pond with closed/locked gate valve and overall site conditions. During the walk around,
necessary actions for the facility to potentially qualify for a No Exposure Certification were discussed.
Facility representatives were informed that a Notice of Deficiency would be issued for failing to conduct and record
Qualitative Monitoring during the second half of 2021.
Page 2 of 3

Permit: NCG170406 Owner - Facility: Kordsa Inc
Inspection Date: 08/10/2022 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
Stormwater Pollution Prevention Plan
Yes No NA NE
Does the site have a Stormwater Pollution Prevention Plan?
E ❑ ❑ ❑
# Does the Plan include a General Location (USGS) map?
0 ❑ ❑ ❑
# Does the Plan include a "Narrative Description of Practices"?
❑ ❑ ❑
# Does the Plan include a detailed site map including outfall locations and drainage areas?
❑ ❑ ❑
# Does the Plan include a list of significant spills occurring during the past 3 years?
❑ ❑ ❑
# Has the facility evaluated feasible alternatives to current practices?
❑ ❑ ❑
# Does the facility provide all necessary secondary containment?
0 ❑ ❑ ❑
# Does the Plan include a BMP summary?
N ❑ ❑ ❑
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
0 ❑ ❑ ❑
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
0 ❑ ❑ ❑
# Does the facility provide and document Employee Training?
0 ❑ ❑ ❑
# Does the Plan include a list of Responsible Party(s)?
0 ❑ ❑ ❑
# Is the Plan reviewed and updated annually?
0 ❑ ❑ ❑
# Does the Plan include a Stormwater Facility Inspection Program?
N ❑ ❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented?
N ❑ ❑ ❑
Comment:
Qualitative Monitorinq Yes No NA NE
Has the facility conducted its Qualitative Monitoring? ❑ 0 ❑ ❑
Comment: Monitoring not conducted in second half of 2021.
Analytical Monitoring Yes No NA NE
Has the facility conducted its Analytical monitoring? ❑ ❑ E ❑
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ 0 ❑
Comment:
Permit and Outfalls Yes No NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site? E ❑ ❑ ❑
# Were all outfalls observed during the inspection? 0 ❑ ❑ ❑
# If the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ ❑
# Has the facility evaluated all illicit (non stormwater) discharges? 0 ❑ ❑ ❑
Comment:
Page 3of3